It’s Official: Coronavirus Screening and Treatment Covered Pre-Deductible for HDHPs

The Internal Revenue Service and the U.S. Treasury issued guidance this week to employers stating coronavirus screening and treatment can be provided through a high deductible health plan (HDHP) without participants first having to satisfy the plan’s deductible.

According to the American Benefits Council, many companies have been seeking assurances from the federal government that by providing COVID-19 screening on a pre-deductible basis would not disqualify the HDHP from being coupled with an HSA. IRS Notice 2020-15 affirms that an HDHP will not fail to be an HDHP because it provides screening and treatment of the 2019 Novel Coronavirus (COVID-19) without a deductible, or with a deductible below the minimum deductible for an HDHP.

coronavirus screening and testing information for HDHP

For self-insured organizations with an HDHP, this notice allows the plan to cover coronavirus testing at 100% pre-deductible. The guidance also allows the plan to consider costs for coronavirus treatment to be pre-deductible.

Fully-insured organizations should check with your insurance provider to find out how they will be administering coronavirus testing and treatment.

Set Benefit Coverage with Your Plan Administrator

To set the benefit coverage for coronavirus testing and treatment, self-insured organizations will need to determine the coverage level desired (e.g. 100% for screening) and contact the plan administrator. Confirm that the benefits coverage should be applied to all of your organization’s medical plans – not just the HDHP

Communicate with Employees

Once you’ve made the decision to cover COVID-19 testing at 100%, be sure to include that message as you remind employees how to prevent the spread of the coronavirus. Participants in your medical plans should be told:

  • Coronavirus screening is covered at 100% without the deductible
  • Benefits for treatment of coronavirus are included in the plan, without having to satisfy the annual deductible

Vaccinations Continue to Be Preventive Care

Included in IRS Notice 2020-15 is confirmation that vaccinations continue to be considered preventive care and can be covered pre-deductible. Plan participants should be reminded of the importance to receive immunizations according to the CDC’s recommended schedule.

For questions about this topic, contact your Findley consultant or

Published March 13, 2020

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Affordable Care Act Preventative Services Updates for 2019

Section 2713 of the Affordable Care Act (ACA) requires group health plans and health insurers to provide coverage for a variety of preventative care services without any cost sharing requirements (deductibles,coinsurance, and copayments). This list of preventative care receives yearly additions and modifications, which must be integrated into health plans within the following two years. These recommendations are made by organizations such as the U.S. Preventative Services Task Force, Bright Futures, and the Advisory Committee on Immunization Practices. Here are some of the recommendations that must be integrated into health plans for the 2019 calendar year:

  • Preeclampsia screening through blood pressure tests
  • Obesity screenings for children and adolescents 6 years and older
  • Vision screening in children ages 3 to 5 to detect amblyopia or its risk factors
  • Influenza vaccine for adolescents
  • Hepatitis B vaccine for adolescents
  • Human papillomavirus (HPV) vaccine for adolescents

This year’s updates appear to focus on improving women’s health during pregnancy and adolescent health in general. While the list above is not exhaustive, here area few resources if you would like to find out more:

  • A list of all recommendations from the U.S. Preventative Services Task Force may be found here.
  • The approved Periodicity Schedule from Bright Futures may be found here
  • ACIP Vaccine Recommendations and Guidelines may be found here
  • Current preventative services for adults, women, and adolescents may be found here

Questions? Contact the Findley consultant with whom you normally work or Kadin Llewellyn at 419.327.4103,

Posted December 18, 2018

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